Cookie
Policy

Last Updated: October 1, 2025

Phichain Capital LLC (“Phichain”, “we”, “us” or “our”) uses cookies and similar tracking technologies on our websites and investor portals (collectively, the “Sites”). This Cookie Policy explains our use of cookies and similar tracking technologies, in a way that is transparent and consistent with U.S. privacy laws (including the California Consumer Privacy Act, “CCPA”) and international best practices (including the EU General Data Protection Regulation, “GDPR”). This Cookie Policy includes information about the types of cookies we use, the purposes for which we use cookies, when third parties provide cookie services on our behalf, the privacy risks associated with cookies and how to control them, how we protect the personal data we collect through cookies, and how to contact us with questions or concerns. By using the Sites, you consent to the use of cookies in accordance with this Cookie Policy (to the extent allowed by your settings or applicable law). If you do not consent to the use of cookies, you can disable non-essential cookies as described below.

A “cookie” is a small text file that a website asks your browser to store on your computer or mobile device when you visit. Cookies allow a site to remember information about your visit (such as user preferences or login status) and to provide you a more convenient and personalized experience. Cookies may either last just for the duration of your visit (“session cookies”) or for a set period of time after you leave the site (“persistent cookies”). Cookies may be set directly by the website you are visiting (“first-party cookies”) or by a different domain/third-party, such as analytics or advertising providers that a site includes (“third-party cookies”). In addition to cookies, our Sites may use similar tracking technologies like web beacons or pixels – tiny transparent images or snippets of code that can record events (e.g. that you opened an email or visited a page) and are often used in conjunction with cookies for the same purposes. For simplicity, we refer to all these technologies as “cookies” in this Policy.

We use cookies to improve and secure your experience on our Sites, to help us understand and improve the performance of our Sites, and for our marketing and compliance efforts. Some cookies are essential for our Sites to function, but others are optional and help us to analyze how our Sites are used or to customize content for your needs. In general, we do not use cookies to obtain sensitive personal information (like financial account numbers or social security numbers), and we do not store passwords or other highly confidential data in cookies. Any personal data that might be collected through cookies (for instance, IP addresses or unique IDs) is used in accordance with our Privacy Policy and applicable laws. We have described below the different categories of cookies we may use and the purpose of each category.

We may use the following categories of cookies on our Sites:

Strictly Necessary Cookies: These cookies are necessary for the operation of our Sites and for enabling core functionality. These cookies are generally set in response to your actions as you make a request for services, such as logging into the investor portal, navigating our Site, or setting your privacy preferences. They allow you to access secure areas of our Sites, and perform security functions, such as account login, authentication and security. For example, we use a cookie to load balance and maintain the security of our Site, and if you log into a secure area of the Site we use a cookie to maintain your session and authenticate your identity. Strictly necessary cookies do not collect information about you for marketing purposes and are not shared with third parties for those purposes. (Because these cookies are required for our Sites to function, you cannot disable them without affecting how our Sites operate.)

Functional Cookies: These cookies (sometimes called “preferences cookies”) allow our Sites to remember choices you make (such as your user name or the region you are in) and provide enhanced, more personal features. These cookies can be set by us or by third-party providers whose services we have added to our Sites. They are used to enhance your experience of our Sites, remember things like your preferred language or region and other settings, and provide customised features. For example, if our site offers a “remember me” option, or if it saves the layout of your personal dashboard for future visits, it will use a functional cookie to make this feature work. Functional cookies enhance your experience of our Sites, but are not strictly necessary to provide you with services. We currently do not use any functional cookies on our Sites.

Analytics Cookies: These cookies help us to improve and optimise our Sites and the services we provide by giving us an understanding of how visitors use our Sites. Analytics cookies allow us to see how visitors use our Sites – for example which pages are visited most, how visitors move around the Sites, and which errors occur. The information these cookies collect is usually aggregated and anonymous – for example it will tell us that X users visited a certain page or used a certain feature, but it will not tell us who those users are. We use this information to understand user behaviour and to improve our Sites. For example, we may use these cookies to test different design layouts or to see if new features are working as intended (“A/B testing”). Google Analytics is an example of a third-party service we use for this purpose. Google Analytics sets cookies (such as “_ga”, “_gid”) that assign a random ID to your browser so that unique visitors can be distinguished and information about your use of the site can be collected and reported to us in aggregate form. Google has told us that the Analytics data is provided to website owners in a way that does not personally identify individual visitors. (See the Use of Third-Party Services section below for more details about how we use Google Analytics and similar services.)

Advertising/Marketing Cookies: These cookies are used to track your online activities and preferences over time in order to deliver relevant advertisements or promotional content, either on our Sites or on third-party sites (e.g. to show you Phichain ads on other websites). We currently do not host third-party ads on our investor portal or fund website (as a hedge fund, our marketing is limited and targeted to qualified investors). However, for completeness and future planning, we describe this category: Advertising cookies may be set through our site by third-party advertising networks or social media platforms with whom we may partner. They work by uniquely identifying your browser and device, and collecting information about your browsing history and interactions with various websites. This information is used to build a profile of your interests so that you can be shown relevant content or ads elsewhere on the internet. These cookies also help us measure the effectiveness of advertising – for example, by limiting the number of times you see the same ad, and by seeing whether an ad results in a visit or signup. Note: If in the future we use advertising or retargeting cookies, we will ask for your consent where required. You will be able to opt out of such cookies, and we will not share data for advertising purposes without the appropriate disclosures and choices offered to you.

We may use third party service providers to help us with the operation of our Sites and the services we provide, with analytics and with embedded content. These third parties may use their own cookies on your device when you visit our Sites with our permission. The following is a list of some of the main third-party services we use and how they use cookies:

As noted above, we use Google Analytics, a web analytics service provided by Google LLC, to gather and report on how visitors use our Sites. The Google Analytics cookies (including _ga, _gid) record information about how you arrived at our site, the pages you view and how long you spend there so that we can generate reports about website activity and user engagement. The information these cookies collect (including your IP address (which we may have configured Google Analytics to anonymize, where possible)) will be transmitted to and stored by Google on servers in the United States or other countries where Google has facilities. Google will use this information for the purposes of compiling reports for us on our website and other usage metrics. The good news is that Google Analytics does not provide us with any information that directly identifies you (for example, your name or contact details). Google Analytics simply provides us with reports on overall activity and engagement, without identifying individual visitors. However, since Google Analytics does involve a third party tracking and processing data about the visitors to our sites, we take our responsibilities for this under privacy law seriously. We have entered into a data processing agreement with Google and we have configured our Google Analytics account to further restrict Google’s use of your data (for example, we do not allow Google to use our analytics data for its own purposes). You can read more about how Google will process your data by reviewing Google’s Privacy Policy and Google’s information on cookies. You can use the tools discussed in Managing Cookie Preferences below (including browser settings or, if provided, Google’s own opt-out mechanisms) if you do not wish to be included in Google’s measurements.

Embedded Content and Social Media: Our Sites may include embedded content or features from third parties, for example, video content (such as YouTube or Vimeo players), mapping (such as Google Maps) or social media share buttons or plugins (such as LinkedIn or Twitter buttons). When you view or use such third-party content, or even if you simply load a page on our Sites that has this content embedded in it, the third party may set cookies on your device. For example, if we embed a YouTube video on one of our pages, when you watch the video YouTube will use cookies to store your preferences and track the number of video views. A social media “share” or “like” button may also set a cookie to allow that feature to work (and also may be used to track that you visited our Sites). Phichain does not control the use of these third-party cookies and they are subject to the privacy/cookie policies of the third-party services themselves. We suggest you consult the policies of each third-party service to understand how they use cookies and other data. For your reference, we have included the following:

YouTube: If videos are embedded, Google/YouTube cookies (such as YSC, VISITOR_INFO1_LIVE) may be set to track video play statistics and remember your settings. These are covered under Google’s privacy policy.

Social media: If our site includes share buttons or feeds from services like LinkedIn, Twitter, or Facebook, those services may set cookies or use similar tracking (e.g., to register your share or to recognize you if you are logged into that platform). Please refer to the privacy policies of the relevant social network for details.

Other Third-Party Cookies: Periodically, we may use different tools or plugins to improve the website (for example, a customer support chat application, or a security/captcha service to stop bots from accessing the website). If any of these tools place cookies on your device, we will inform you of this policy or on the interface of the tool itself, as well as ensure you can control any such cookie, if necessary, under applicable law. As of the date of this Policy, our main use of third-party cookies is for analytics (as described above) and for standard embedded content. We do not currently use third-party advertising networks that collect information via cookies on the website.

Third-Party Data Use and Privacy: When we permit a third-party service to place cookies or collect information through our Sites, we ensure they process your information securely. We only work with trusted providers and, where appropriate, we have contracts with them (such as Data Processing Addendums) that limit their ability to use the data they collect from our Sites. For example, cookies placed on our Sites by our analytics or service providers are not permitted to be used by those third parties for their own purposes not related to the service we have requested. However, as is the case with cookies on most other sites, your use of any third-party cookies on our Sites is still subject to the privacy policies of those third parties. We encourage you to read our Privacy Policies as well as those of third parties with which we may share data. We also want to be clear that we do not sell your personal information collected through cookies or other means to any third party (see Your Privacy Rights below for more information on CCPA definitions and commitments in this regard)

Questions, Comments and Requests: If you have any questions, comments or requests about this Cookie Policy, or our use of cookies and similar technologies, please contact us. We would be happy to assist you. Please email us at sales@Phichain.io if you have any questions about our use of cookies.

Changes to this Policy: We may update this Cookie Policy from time to time, for example to reflect changes to the cookies we use or for legal compliance purposes. If we make changes to this Policy, we will update the “Last Updated” date at the top of this Policy. If the changes are material, we may provide a more prominent notice (for example, by posting a notice on our Website or sending an email to you where appropriate). We encourage you to review this Cookie Policy regularly to keep up-to-date with our use of cookies. If you continue to use our Sites after we have posted changes to this Cookie Policy, you agree to be bound by the revised Policy to the extent permitted by law.

Phichain Capital LLC believes in providing a clear and comprehensive Cookie Policy in order to show our commitment to privacy, transparency, and user choice. Thank you for taking the time to read this Cookie Policy. We appreciate your privacy and trust, and are committed to protecting your data while providing you with the highest quality experience online.

As with any personal data you share with Phichain, we take steps to protect the information we collect through the use of cookies. This includes a range of technical and organisational security measures that are designed to help prevent cookie data (which may include personal information) from being accidentally lost, used, disclosed, altered or destroyed without our authorisation, or from unauthorised access, disclosure, modification or use. These security measures help protect all information we process against such risks, whether it is stored on our systems or in transit to / from our systems, including encryption, firewalls and other technical security measures; strict access controls and other measures to restrict access to data on a need-to-know basis; and training our staff on privacy and security best practices. Our security processes also treat any information we collect through cookies and analytics as confidential information. For analytics cookies, although the information we collect is aggregated for analytical purposes, any raw data (such as IP addresses or unique IDs) that could be considered personal is held behind our security controls. Where we work with third party service providers to process cookie data on our behalf, we also require them to have appropriate security measures in place to protect that information; for example, our contracts with analytics providers require them to use appropriate security measures to protect any data they process in a manner consistent with applicable law.

We also apply data minimisation and retention principles to cookies. Cookies themselves have set lifespans (as detailed in the cookie descriptions above or set by the provider who placed the cookie) – we therefore do not generally have access to the personal data they store for longer than necessary (or permitted by applicable law). For example, if we set a cookie to expire in 6 months’ time, the information stored in that cookie will automatically be deleted from our systems when it expires and become inaccessible to us unless we re-set that cookie with your permission. We also periodically review the cookies used on our Sites and remove or disable any that are no longer needed. If a cookie is used to store your preferences (such as an opt-out preference), we may extend its lifespan in order to ensure we are able to respect your preferences for as long as necessary; otherwise, we aim not to keep cookies (or the data we collect through them) for longer than necessary.

In addition, as mentioned above in Managing Cookie Preferences, you can delete cookies at any time; if you delete our cookies, we will no longer have access to the information those cookies contain. In some cases, if you request that we delete your personal data in accordance with privacy laws and that information can only be identified through cookies, we may direct you to delete or reset those cookies as part of the process of responding to your request.

In short, we have security measures in place to protect data we collect through the use of our Sites from being lost, used, disclosed, altered or destroyed without our authorisation. As with any system, we can’t guarantee that data will be 100% secure at all times, but we monitor our systems and adapt our security practices and infrastructure as necessary to respond to new and emerging threats and maintain a high level of protection.

As cookies may involve processing of personal data (online identifiers, usage data and such may be considered “personal data” under certain privacy laws), we want to make sure you are aware of your rights in relation to such data. Phichain is committed to complying with all applicable privacy laws, including the CCPA (as amended by the California Privacy Rights Act “CPRA”) and, to the extent applicable, the GDPR. Below is an overview of how those laws relate to our use of cookies:

California Residents – CCPA/CPRA: If you are a resident of California, you have certain rights under the CCPA/CPRA law in relation to your personal information. This includes the right to know what personal information we collect, the right to request deletion of your personal information, the right to opt out of the “sale” or “sharing” of your personal information, and more. Under the CCPA’s broad definitions, identifiers collected via cookies (such as a persistent unique ID, an IP address or other online identifier) are considered “personal information”. Additionally, disclosures of cookie data to certain third parties could be construed as a “sale” of personal information even where no money is exchanged – for instance, if a company allows third-party advertising or analytics cookies on its site in exchange for services or some other type of value, that arrangement may qualify as a sale under CCPA’s definitions. Phichain’s policy is that we do not “sell” personal information as that term is defined in CCPA, and this includes information collected through cookies. We do not share your cookie data with third parties for their own independent use (outside of the service provider context described earlier in the notice). Any third parties who receive cookie data (such as our analytics providers) are engaged as “service providers” or “contractors” under the law, meaning they are contractually obligated to limit their use of the data to providing the services we’ve requested and to not further share the data. This relationship is intended to fall under the CCPA’s “service provider” exception, so that our use of analytics/functional cookies is not characterized as a “sale” of personal information. Still, out of an abundance of caution, we provide you with the ability to opt out of non-essential cookies (via our banner or preferences center) in case you wish to exercise an opt-out of any potential “sale”/“sharing” – for instance, by opting out of analytics cookies you effectively cut off the data flow to third parties in ways that could be seen as a sale. Additionally, we recognize and honor Global Privacy Control (GPC) signals from California residents as required by California law: if our website detects a GPC signal from your browser or extension, we will interpret this as a valid opt-out request regarding the sale/sharing of personal information via cookies, and will disable non-essential cookies for that browser henceforth. (Learn more about GPC at globalprivacycontrol.org.) If you are a California resident and have further questions regarding our cookie use or your rights under the law, please contact us as indicated in the Contact Us section below. You can also visit our more comprehensive Privacy Notice for California Residents for a full rundown of your rights under CCPA/CPRA and how to exercise them.

Individuals in the European Economic Area (EEA), United Kingdom, or Other Regions – GDPR: If you are a resident of the EEA, UK or any other jurisdiction with similar data protection laws, the GDPR (or local law equivalent, if applicable) grants you rights in relation to your personal data. These rights include the right to consent or object to processing of your data, the right to access your data, the right to request its erasure, and others. In the context of cookies, we specifically draw your attention to the right to choose whether non-essential cookies are placed on your device. In compliance with GDPR and ePrivacy directives, we use a consent banner for users in applicable regions that requires an opt-in (a clear affirmative action) before we are allowed to set analytics, advertising or other non-strictly-necessary cookies. You can withdraw your consent at any time – if you have previously given your consent for certain cookies, you can change your mind at any time by visiting our Cookie Preference Center and we will stop further data collection through those cookies (note that withdrawing consent does not delete cookies already placed on your device, only prevent future data collection – to remove those cookies, you may need to manually delete them via your browser). Any personal data that we may collect through cookies (such as an IP address or device identifier tied to our analytics) is managed in compliance with GDPR principles of lawfulness, transparency, purpose limitation and security. We use consent as a lawful basis for non-essential cookies where necessary (that is, in countries that require cookie consent for such cookies, we rely on users providing consent to set such cookies), and we use our legitimate interests (or equivalent lawful basis) for any cookies that are exempt from consent (such as using necessary cookies to make our site work securely is in our legitimate interest). If you believe that our use of cookies in any way involves personal data that you have provided to us and you wish to exercise other rights under GDPR (such as accessing such data, requesting erasure or deletion of such data, or portability of such data), please do not hesitate to contact us. Typically, data collected via cookies that can be linked to an identifiable person (such as online identifiers) is pseudonymous and not directly linked to your real-world identity in our records. However, in the event you submit a data subject request under GDPR, we will make good-faith efforts to search for and remediate data relating to you, if any, to the extent required by law. For more information on how we process personal data and your full range of rights, please refer to our main Privacy Policy and/or GDPR-specific notice.

Other Jurisdictions: Phichain is a U.S.-based company, but we know that people from all over the world may visit our Sites. We try to follow privacy-by-design and transparency principles voluntarily, even in jurisdictions where specific cookie laws may not apply to us. For instance, even if we’re not legally required to provide cookie choice mechanisms to users in your region, we may do so anyways, because we respect your privacy and value your trust. If you are a user from a region with specific privacy laws (such as Canada’s PIPEDA, Brazil’s LGPD, etc. ), and you have any questions or requests in relation to our use of cookies or personal data, please don’t hesitate to contact us. We will do our best to address your concerns and ensure compliance with all applicable legal requirements

As a general policy, we allow you to decide what cookies are used. Upon your first visit to our Sites (or when you return to our Sites after deleting cookies stored on your device), you will see a cookie notice or banner. The cookie notice or banner will provide you with information about our use of cookies and seek your consent to store any non-essential cookies on your device. For example, the cookie banner will allow you to accept or reject different categories of cookies (such as analytics or advertising cookies), as required by applicable law. We will not use non-essential cookies on your device without your affirmative consent in those jurisdictions where consent is required for such use (such as the EU/EEA, United Kingdom, etc.). In other jurisdictions (for instance, within the United States, but outside of states with their own specific consent requirements), we will, to the extent permitted by law, consider your continued use of our Sites after having received our cookie notice as consent to use cookies; in any event, you will still be able to change your preferences at any time.

Cookie Preference Center: In addition to making your initial choice, you can also change your cookie settings on our Sites at any time. We have a Cookie Preference Center (you can access the Cookie Preference Center by clicking on a “Cookie Settings” or “Manage Cookie Preferences” link in the footer of the website) where you can review and update your current consent status. You can update your preferences and choose to opt in or opt out of non-essential cookie categories at any time through the Cookie Preference Center. Your updated choices will be applied immediately. Note that we cannot disable certain cookies (especially Strictly Necessary Cookies) via our preference center, as these cookies are necessary for the operation of the site.

Browser Settings: In addition to the controls we provide on our websites, you can also adjust your browser settings to manage cookies. Most browsers allow you to see the cookies that are placed on your device and delete them on an individual or aggregate basis. Browsers also typically provide cookie management tools that allow you to block or restrict cookies from certain sites or from all sites (such as blocking all third-party cookies or being notified when a cookie is about to be placed on your device). You can generally set your browser to do this, but please refer to the help or settings section of your browser (common browsers like Chrome, Firefox, Safari, Edge, etc. should have online help available on their cookie management options) to learn how this works on your browser. The exact navigation path to the settings will vary from browser to browser, but they are typically found under the “Privacy” or “Security” options. A few examples (non-exhaustive and non-exhaustively described) are listed here for convenience: * Google Chrome Help – Clear, enable, and manage cookies . * Mozilla Firefox – Delete cookies to remove the information websites have placed on your computer. * Microsoft Edge – Clear cookies.

Please note that if you disable or block certain categories of cookies (or all cookies) via your browser settings, our site (and many other websites, as well) will not operate as intended. Note especially that disabling all cookies (including necessary cookies) will cause certain functionality and services on our Site to no longer be available to you. For instance, blocking our strictly necessary cookies will prevent you from logging in to the investor portal or using certain features of our site. For this reason, we recommend that you at least allow the use of necessary cookies. Blocking non-essential cookies will not impact your basic use of our Sites, but it will limit our ability to personalize your experience and to analyze the use of our services.

Opting Out of Analytics: In addition to using our website preference center or your browser settings, you can opt out of Google Analytics by installing a plugin offered by Google that will prevent Google Analytics script from gathering information about your use of any site that implements GA. You can get the plugin (and read Google’s instructions for how to use it) on the Google web page at tools.google.com/dlpage/gaoptout . Note that this opt-out plugin is browser-specific – so if you use multiple browsers or devices, you will need to install it in each one. Also, if you clear your cookies you may need to reset some of your opt-out choices (although the Google Analytics plugin should persist until you uninstall or disable it).

Effects of Disabling Cookies: If you choose to disable certain categories of cookies on our Sites (or all cookies through your browser), please note that you will have a more limited experience on our Sites. In particular, as mentioned above, essential services like authentication, security or remembering your cookie preferences may not function properly if those cookies are blocked. Although we strive to ensure our Sites remain useful even to those who do not accept our use of cookies, certain aspects of our Sites will not work without cookies and other related technologies. For example, if you turn off functional cookies, you will need to reset your cookie preferences each time you visit the Sites. If you turn off our analytics cookies, you will not be able to use our Sites (which you can do without these cookies), but it will make it difficult for us to understand how people are using our services (since we will not be able to see usage statistics). If you were to turn off all cookies through your browser settings (including necessary cookies), some portions of our Sites will be inaccessible to you. If you have a modern browser, you can also consider using per-site cookie settings to decide what cookies to accept for which sites. This can be a more granular approach to managing your privacy, as you can for instance allow cookies from the sites that you use and trust, and block them from sites that you do not use frequently or trust.

We hope this has helped you understand the reasons why we use cookies and the purposes they help us with. However, it is also important to be mindful of the potential privacy and security risks associated with cookies – particularly those non-essential cookies, such as analytics cookies and advertising cookies. Privacy Risks: Cookies, particularly third-party tracking cookies, can be used to build a detailed profile of a user’s online activities. By tracking your browsing activity across different sites, third-party cookies can accumulate a significant amount of information about your interests, preferences, and online behavior. This practice can raise serious privacy concerns, as users may not be aware of the extent of the information being collected about them. For example, if you had enabled marketing cookies, the advertising networks could have used the data from cookies to make inferences about sensitive information (such as your purchasing habits, health concerns, or political leanings) and associate it with you as a unique user or potentially even with your identity in some cases. Security Risks: There are also security considerations to be mindful of. Cookies could be accessed by malicious actors to track users for malicious purposes or potentially to hijack sessions if vulnerabilities are present. In some cases, poorly secured cookies might be exploited to steal personal data or to insert malicious content. Furthermore, tracking with the help of cookies often occurs invisibly in the background, and users may not know that their browsing activity is being monitored or even manipulated. As our user, we want you to be aware of the potential privacy and security risks so that you can make informed decisions about your cookie preferences.

Our risk mitigation measures: Phichain is committed to mitigating the privacy and security risks related to cookies. We limit our use of cookies to what we believe is necessary for our business and operational purposes. We don’t use intrusive third-party advertising trackers that profile users across unrelated websites. The third-party analytics tools we use are configured to collect as little unnecessary personal data as possible (e.g., we may anonymize IP addresses, and don’t send PII through analytics, etc. ), and are governed by strict agreements. Furthermore, any personal data we collect with the help of cookies is handled in accordance with our Privacy Policy and applicable law, as with any other personal data we collect – this means that it is only used for specified, legitimate purposes and we implement appropriate technical and organizational security measures to protect it from unauthorized access, disclosure, alteration, or destruction. This includes industry-standard safeguards such as encryption of data in transit, regular security testing of our website, and limiting access to data, among other measures. We also monitor changes in privacy regulations and browser technologies (such as browser-driven tracking protections) to ensure we adapt our practices and stay compliant. In summary, while no technology is without risk, we aim to use cookies responsibly and provide you with control over non-essential cookies to address your privacy concerns.

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